Privacy Policy

Last Updated: October 21, 2026

PLEASE READ THIS WEBSITE PRIVACY POLICY (“POLICY”) CAREFULLY. THIS POLICY CONSTITUTES A LEGALLY BINDING AGREEMENT BETWEEN YOU AND PINE VALLEY CAPITAL PARTNERS LLC, A TEXAS LIMITED LIABILITY COMPANY (“PINE VALLEY CAPITAL,” “WE,” “US,” OR “OUR”). BY ACCESSING, OR USING THE PINE VALLEY CAPITAL WEBSITE OR ANY RELATED SERVICES (COLLECTIVELY, THE “WEBSITE”), YOU AGREE TO BE BOUND BY THIS POLICY. IF YOU DO NOT AGREE TO THIS POLICY, DO NOT USE THE WEBSITE.

This Policy explains the manner in which we collect, utilize, disclose, store, and maintain nonpublic personal information of visitors to and users of the website, as well as the Client’s/Funds’ investors, as required under federal regulation. Although federal regulation provides that the usage of nonpublic information of investors (“Investor Information”) is limited to investors who are individuals, we apply this Policy to all of our investors. As used in this Policy, “personal information” shall mean information that identifies, relates to, describes, or could reasonably be linked, directly or indirectly, with a particular individual or household. “Investor Information” shall mean personally identifiable financial information including any list, description or other grouping of our investors that is derived using nonpublic personal information other than publicly available information. Specifically, for the purpose of this policy, Investor Information includes, but is not limited to, an investor’s name, social security number or taxpayer identification number, contact information (including home address, business address, telephone number and date of birth), financial and investment qualifications or account number with us. To the extent personal information also constitutes Investor Information, the more protective provisions described herein apply.

A. Privacy Regulation

The SEC’s Regulation S-P (Privacy of Consumer Financial Information, herein after the “Privacy Rules”), which was adopted to comply with Section 504 of the Gramm-Leach-Bliley Act, requires investment advisers to disclose to their investors our policies and procedures regarding the use and safekeeping of investor records (“Privacy Notice”).

Among other requirements, the Privacy Rules require financial institutions to send initial Privacy Notices to “consumers,” send annual Privacy Notices to “customers” and provide both customers and consumers the opportunity to opt out of the disclosure of any non-public personal information about a consumer to a nonaffiliated third party. For purposes of this Policy, “consumers” are potential and current investors in the Clients/Funds and “customers” are the Clients’/Funds’ current investors.

In addition to the Privacy Rules, our handling of personal information is designed to comply with applicable U.S. federal and state privacy laws.

B. Collection of Investor Information

We collect personal and/or confidential information about investors mainly through the following sources:

• Subscription documents, investor questionnaires and other information provided by the investor in writing, in person, by telephone, electronically or by any other means. This information includes name, address, nationality, tax identification number and financial and investment qualifications.
• Internal transactions, including account balances, investments, and redemptions.

Information Collected Through Our Website Contact Form

When you submit our contact form, we collect: your full name; email address; telephone number; and the content of your message and any information you choose to include. Submitting the form is voluntary. We collect only information reasonably necessary and proportionate to respond to your inquiry (data minimization).

Please do not include sensitive personal information (e.g., Social Security number, financial account numbers, driver’s license or passport numbers, health information, precise geolocation, racial or ethnic origin, religious beliefs, citizenship or immigration status, biometric or genetic data, or account login credentials) or Investor Information in your message; if you do, we will handle it in accordance with this Policy and applicable law and may delete it. We do not knowingly collect sensitive personal information through the Website.

No Cookies or Tracking Technologies

The Website does not use cookies, web beacons, pixels, tags, scripts, device fingerprinting, analytics tools, advertising identifiers, session replay, or any similar tracking technologies, and we do not collect information about your browsing activity on the Website or across third-party sites over time. We do not engage in targeted advertising or cross-context behavioral advertising. Our hosting provider’s servers may automatically generate standard technical logs (e.g., IP address, date/time of request) strictly as needed to deliver and secure the Website; we do not use such logs to identify or profile visitors.

Do Not Track and Universal Opt-Out Signals

Because we do not track users over time or across third-party websites, we do not respond differently to “Do Not Track” browser signals; there is no tracking to disable. Because we do not sell personal information or process it for targeted advertising, a universal opt-out mechanism such as Global Privacy Control has no additional effect.

C. Disclosure of Nonpublic Personal Information

We do not sell or rent Investor Information. We do not disclose Investor Information to nonaffiliated third parties or to affiliated entities, except as permitted by law. For example, we may share Investor Information in the following situations:

• To service providers in connection with our administration and servicing, including attorneys, accountants, auditors, and other professionals. We may also share information in connection with the servicing or processing of our transactions.
• To respond to a subpoena or court order, judicial process, or regulatory authorities.
• To protect against fraud, unauthorized transactions (such as money laundering), claims or other liabilities.
• Upon consent of an investor to release such information, including authorization to disclose such information to persons acting in a fiduciary or representative capacity on behalf of the investor.

We do not sell personal information, do not share it for cross-context behavioral advertising, and do not process it for targeted advertising; we have not done so in the preceding 12 months. We do not sell sensitive personal data. We may disclose personal information only:

• To service providers and processors (e.g., website hosting, email providers) bound by written contracts to process it only on our instructions and keep it confidential and secure;
• To respond to subpoenas, court orders, legal process, or regulatory authorities;
• To protect against fraud, security incidents, or legal claims;
• In connection with a merger, acquisition, or sale of assets, subject to confidentiality protections; or
• With your consent.

We do not disclose personal information to third parties for their own marketing purposes.

How We Use Personal Information

We use personal information for the following purposes:

• To respond to your inquiry and communicate with you by email or phone;
• To evaluate and follow up on requests concerning our services;
• To maintain records of communications as required by applicable law and regulation;
• To maintain the security and integrity of the Website and prevent fraud; and
• To comply with legal obligations.

We will not use personal information for purposes not reasonably necessary to or compatible with these purposes without your consent.

Marketing emails: We will send commercial email only in compliance with CAN-SPAM (accurate header and subject, identify as advertisement, physical address, unsubscribe link honored within 10 business days); you may opt out at any time by contacting us at hello@pvcapitalpartners.com.

D. Protection of Investor Information

Our policy is to require that all Supervised Persons, financial professionals, and companies providing services on their behalf keep Investor Information confidential. We maintain safeguards that comply with federal standards to protect such information. We restrict access to the Investor Information to those Supervised Persons who need to know that information in the course of their job responsibilities. Third parties with whom we share Investor Information must agree to follow appropriate standards of security and confidentiality. This Policy applies to both current and former investors. We may disclose Investor Information about a former investor to the same extent as for a current investor.

Protection of Personal Information

We maintain reasonable administrative, technical, and physical safeguards appropriate to the nature of the data we collect and maintain, including encryption in transit (TLS/HTTPS) for contact-form submissions, access controls limited to personnel who need the information to respond, and vendor oversight. No method of transmission over the Internet is 100% secure.

Data Breach Notification: If a data breach involving your personal information occurs, we will notify affected individuals as required by applicable state laws.

E. Location and Maintenance of Investor Information

All Investor Information is retained in accordance with our “Record Retention Policy.” All Investor Information is kept only in a secure location with limited access.

Storage and Retention of Personal Information

Personal information is stored on secure servers and systems located in the United States maintained by us or our service providers. Contact-form submissions and related correspondence are retained for no longer than reasonably necessary to respond to and resolve your inquiry and thereafter for three (3) years, or longer if required by applicable law, regulation (including our recordkeeping obligations under its Record Retention Policy), or legal hold. Retention criteria include: purpose of collection, legal and regulatory requirements, and applicable statutes of limitation. Upon expiration, information is securely deleted or de-identified, consistent with the disposal methods in Section H.1. We will maintain de-identified data without attempting to re-identify it.

F. Initial Privacy Notices

We provide new investors with a Privacy Notice describing our privacy policy and obtain and retain written evidence that such notice was provided prior to making the investment.

G. Distribution of Privacy Notices Upon Material Change

We or a designee (e.g., a fund administrator) distribute to all of our investors a Privacy Notice describing our privacy policy upon any material changes.

We also will post any updated Policy on the Website with a revised “Last Updated” date; for material changes we will provide prominent notice on the Website and, where we have your email address and if required by law, notify you by email.

H. State Privacy Laws

Certain states have adopted privacy regulations that may be applicable to advisers with investors who are residents of those states. We periodically review such laws and evaluate our procedures and controls. To the extent necessary, we will revise our procedures and institute additional controls in order to comply with applicable state privacy laws.

1. Massachusetts Information Security Regulations

The Massachusetts Standards for the Protection of Personal Information (201 CMR 17.00) (the “Standards”) applies to all firms that maintain personal information about a Massachusetts resident regardless of location. As such, financial services firms such as investment advisers with access to “personal information” (as defined below) about a Massachusetts resident generally must meet the Standards.

Under the law, “personal information” to be protected includes a Massachusetts resident’s name (either first and last name or first initial and last name) combined with a complete social security number, driver’s license, or other state-issued number, a financial account number or a complete credit card or bank account number.

We have established the following procedures in relation to protecting Client data:

• Assess information security risks on an ongoing basis;
• Terminate access to information by former Employees;
• Oversee service providers;
• Place reasonable restrictions on physical records;
• Implement secure user authentication and access controls for electronic systems;
• Encrypt, where feasible, all electronically transmitted records;
• Maintain up-to-date virus definitions, firewall protections, and operating system security patches;
• Provide initial and ongoing training to Employees; and
• Document the responses to information security breaches and records of corrective actions taken as a result of the breach.

We dispose of such non-public personal information in a secure fashion when it is no longer required for record keeping requirements.

2. Your Privacy Rights

Subject to applicable law and verification of your identity, you may have the right to:

• Confirm whether we process your personal information and access it;
• Obtain a portable copy of your personal information;
• Correct inaccuracies in your personal information;
• Delete personal information you provided or that we obtained about you;
• Opt out of the sale of personal information, targeted advertising, and profiling in furtherance of decisions producing legal or similarly significant effects (we do not engage in these activities).

California residents may also request disclosure of the categories and specific pieces of personal information collected, the categories of sources, the business purposes for collecting or selling, and the categories of third parties to whom personal information was disclosed, covering the prior 12 months, and may limit the use of sensitive personal information (we do not use sensitive personal information beyond permitted purposes).

3. How to Exercise Your Rights

To submit a privacy rights request, you may contact us by:

• Email: hello@pvcapitalpartners.com with the subject line “Privacy Rights Request”; or
• Mail: 401 S 1st Street, Suite 750, Austin, Texas 78704.

Please provide your name, email address or other contact information, and the nature of your request. We verify your identity by matching the information you provide with information we hold. Authorized agents may submit requests with signed written permission or a valid power of attorney; we may require the consumer to verify his or her identity directly.

Response timing: We will respond within 45 days, which may be extended once by an additional 45 days when reasonably necessary, with notice to you. Requests are free of charge up to twice per 12-month period, unless the request is manifestly unfounded, excessive, or repetitive.

4. Right to Appeal

If we decline to act on your request, we will explain the reasons for our decision and inform you of your right to appeal. You may appeal by emailing hello@pvcapitalpartners.com with the subject line “Privacy Rights Appeal” within a reasonable period. We will respond in writing within 60 days explaining our decision. If your appeal is denied, Texas residents may contact the Texas Attorney General at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.

5. Non-Discrimination

We will not deny goods or services, charge different prices, provide a different level or quality of goods or services, or suggest that we may do so, because you exercised any of your privacy rights.

Children’s Privacy

The Website is not directed to children under the age of 18. We do not knowingly collect personal information from children under 18, and do not knowingly process personal data of a known child. If we learn that we have collected personal information from a child under 13, we will delete it promptly. If you believe that a child has provided personal information to us, please contact us at hello@pvcapitalpartners.com with the subject line “Removal of Minor Information.”

Third-Party Links

The Website may contain links to third-party websites or services that are not owned or controlled by us. This Policy does not apply to those third-party websites. We encourage you to review the privacy policies of any third-party websites you visit.

Accessibility

This Policy is available in alternative formats upon request. Please contact us at hello@pvcapitalpartners.com to request an accessible version.

Contact Us

If you have questions about this Policy, please contact us:

Pine Valley Capital Partners LLC
401 S 1st Street
Suite 750
Austin, Texas 78704
Email: hello@pvcapitalpartners.com

Please use the subject line “Question: Privacy Policy” for privacy-related inquiries.